December 11, 2006 VIA EDGAR AND FACSIMILE Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Ms. Barbara C. Jacobs Ms. Rebekah Toton RE: ISILON SYSTEMS, INC. REGISTRATION STATEMENT ON FORM S-1 FILE NO. 333-137078 ACCELERATION REQUEST REQUESTED DATE: DECEMBER 13, 2006 REQUESTED TIME: 2:00 PM EASTERN TIME Mesdames: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Isilon Systems, Inc. (the "Company") hereby requests that the above-referenced Registration Statement on Form S-1 (File No. 333-137078) be declared effective at the "Requested Date" and "Requested Time" set forth above or as soon thereafter as practicable or at such later time as the Company may request by telephone to the Commission. The Company hereby authorizes both Craig Sherman and Mark J. Handfelt of Wilson Sonsini Goodrich & Rosati, P.C., counsel for the Company, to make such request on our behalf. In connection with the acceleration request, the Company hereby acknowledges that: - Should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; - The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and - The Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Sincerely, ISILON SYSTEMS, INC. By: /s/ Steven Goldman --------------------------------- Steven Goldman Chief Executive Officer cc: Douglas Choi ISILON SYSTEMS, INC. Craig Sherman Mark J. Handfelt WILSON SONSINI GOODRICH & ROSATI, PROFESSIONAL CORPORATION Laird H. Simons, III, Esq. Jeffrey R. Vetter, Esq. FENWICK & WEST LLP